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Refrigerants (e.g. R134a, R407c, R410a) are used in refrigeration and air-conditioning equipment such as chillers, air conditioners and heat pumps. These fluids are the source of certain greenhouse gases (GHGs). In order to control and reduce GHG emissions, refrigerant management regulations are becoming increasingly stringent.
Within this framework, a decree dated February 29, 2016 sets out the rules for their management and the equipment containing them (leak checks on equipment, terms and conditions for the disposal of fluids, the content and terms of use of the intervention sheet, ...). Since then, 4 decrees have been issued to amend the regulations (in July and December 2016, then in March and April 2017). In this article, we take a look at the main changes brought about by these 4 decrees.
Changes to refrigerant leak detectors (July 2016)
As a reminder: a leak detector is a permanent device which analyzes at least one of the following parameters: pressure, temperature, compressor current, liquid levels, or the volume of the quantity recharged. It is linked to an alarm that informs the operator of equipment containing refrigerants of any leak detected.
In July 2016, the alarm trigger threshold was changed and time limits for searching for refrigerant leaks using direct measurement methods were introduced.
New version of CERFA 15497 form (December 2016)
Reminder: the operator (the service provider) must fill in an intervention form for each operation involving the handling of refrigerants on equipment. Cerfa 15497(1) sets out the model form to be used in most cases (2). This Cerfa also serves as the Bordereau de Suivi des Déchets Dangereux (BSD) (hazardous waste tracking slip) for fluid disposal, whatever the quantity of fluid in the equipment, and for all categories of activity(2).
In December 2016, version 2 of the CERFA 15497 form was published. It has been in use since December 30, 2016. This new version allows:
- consistency of the intervals (and in particular the notion of less than or equal to) defining the regulatory leak test periods with those defined in the Order of February 29, 2016,
- the possibility of entering a different UN code and ADR name for the refrigerant waste than in the general case,
- color-coded distinction of the boxes to be filled in, depending on whether the operation involves work on equipment and/or the removal of refrigerants from equipment for treatment in an authorized facility.
- the integration of new appendices to take account of the following two scenarios:
A copy of the BSD must be returned within one month, by the waste treatment facility, once the treatment has been completed:
- the equipment holder, if the waste was shipped without collective collection,
- to the collector (operator/provider) in the case of small quantities, using Appendix I.
Non-mandatory nature of standards for leak testing (March 207)
The standards quoted for leak testing concern operators holding a certificate of competence to carry out these tests (who may be service providers or your own staff).
References to these standards have been reworded. From now on, these standards are cited by way of example. Their implementation is no longer compulsory, but they can be used as a means of meeting the requirements set by the decree for carrying out tightness checks.
Limiting the duration of use of leaking equipment (April 2017)
The use of equipment containing fluorinated greenhouse gases on which a leak has been detected during a leak test is now limited to 4 working days. Within this period :
- or measures are taken to stop the leak;
- or the equipment is shut down and emptied by a certified operator.
The equipment can only be put back into service once the leak has been repaired. If the equipment consists of several circuits, the circuits or parts of circuits on which no leak has been detected may remain in service. These obligations do not apply if shutting down the equipment would compromise the safety or security of ICPE (Installations Classées pour la Protection de l'Environnement) or basic nuclear installations. In such cases, the equipment cannot be recharged with refrigerant until it has been repaired.
Our advice for equipment containing refrigerants
If you own equipment containing refrigerants (e.g. R134a, R407c, R410a), these changes need to be taken into account when managing this equipment, particularly when carrying out leak checks, in the event of refrigerant leaks or operations requiring refrigerant handling.
If you have procedures or instructions in place, it may be useful to update them. Likewise, it may be useful to discuss these "new features" and their implementation on your equipment with your service provider.
(1) Cerfa 15497 definition: "Fiche d'intervention / Bordereau de suivi de déchets dangereux pour les opérations nécessitant une manipulation de fluides frigorigènes effectuées sur un équipement".
(2) This Cerfa 15497 is to be used if the operation falls into category I, II, III or IV. It serves as a BSD for all categories, including n°V.
The categories of activities are set out in the order of June 30, 2008:
- Category I: leak testing, maintenance and servicing, assembly, commissioning, fluid recovery for all refrigeration, air-conditioning and heat pump equipment.
- Category II: maintenance and servicing, assembly, commissioning, fluid recovery of refrigeration, air-conditioning and heat pump equipment containing less than 2 kg of refrigerant, and leak testing of refrigeration, air-conditioning and heat pump equipment.
- Category III: Recovery of fluids from refrigeration, air conditioning and heat pump equipment containing less than 2 kg of refrigerant;
- Category IV: Leak testing of refrigeration, air conditioning and heat pump equipment;
- Category V: leak testing, maintenance and servicing, assembly, commissioning, fluid recovery for air-conditioning systems on vehicles, machines and equipment mentioned in article R. 311-1 of the Highway Code.